ML19341A483

Petition for Leave to Intervene

ML19341A483
Person / Time
Site:	Wolf Creek
Issue date:	01/19/1981
From:	Davis L, Mason J, Mills C KANSANS FOR SENSIBLE ENERGY
To:	NRC COMMISSION (OCM)
References
NUDOCS 8101230638
Download: ML19341A483 (3)

Text

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s 30CKET NUNSER RO. BOX 3192

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• CHITA, KANSAS 67201 UNITED STATES OF AMERICA

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In the matter of MU N Kansas, Gas,and Electric &

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Kansas City Power & Light 2ndatlet (Wolf Creek Plant Unit 1) g PETITION TO INTERVENE 9

We the undersigned; representing Kansens for Se e

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Energy (hereinaf ter "KASE"), a citiJens group of pi who will be directly affected by the operation of

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Wolf Creek Nuclear ?ower Plant near Burlington, Kans s' 42 do hereby petition the Nuclear Regulatory Commission to ' N 'I '

intervene in the matter of an operating license f or the Wolf Creek plant.

KASE has been actively engaged in the promotion of con-servation and alternative energy sources, as well as actively opposed to nuclear power for several years.

Activities include f ormal intervention in the Wolf Creek KEPCO hearings bef ore the Kansas Corporation Commission 5

g (KCC), participation on the KCC Consumer ~ Information Board, and testimony given during K.G.&E. rate requests before the KCC.

0 Reasons for Intervention 4

1.

Numerous construction problems have made safe operation of the plant questionable.

These include a con-AcC ;_1 by cord... /[/

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m RO. BOX 3192 WICHITA, KANSAS 67201' crate base met which is riddled with voids and had some test sections which failed to meet manufacturer's speci-fications'for strength.

Also welding defects in the embeds of the SNUPPS designed Calloway, miscouri plant brings into question the embeds of the SNUPPS designed Wolf Creek plant.

2 K.G.&E. has no plan for the permanent storage of nuclear wastes, nor is there a viable plan f or dacommi-sioning the plant when its operating lif e is over.

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No adequate evacuation plan exists f or residents who would be aff ected in the case of a major incident at the plar.t.

4 Eastern Kansas has suffered a very dry year and, if dry conditions persist, the water used for the Wolf Creek cooling lake could have an adverse eff ect on the B

5 envir'anment of Eastern Kansas.

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In estimating the chances of a reactor accident, M*

the original Environmental Impact Study used the relie-bility estimating techniques of the Rasmussen report, o

which have since been proven invalid.

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6 ME RO. BOX 3192 WICHITA, KANSAS 67201 REASON WHY PETITIONER SHOULD BE ALLOWED TO INTERVENE.

KASE is able to bring to this proceeding evidence and witnesses with respect to the operation of the Wolf Creek plant as it relates to saf ety and the environment which may not be included if KASE is not granted intervenor status.

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